1 in the United States District Court Western District Of
Case 1:19-cv-00885-ADA Document 30 Filed 09/18/19 Page 1 of 59 IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS AUSTIN DIVISION FRESHUB, INC., a Delaware Corporation, and ) FRESHUB, LTD., an Israeli Limited Liability ) Case No. 1:19-cv-00885-ADA Company, ) ) DEMAND FOR JURY TRIAL Plaintiffs, ) vs. ) ) AMAZON.COM, INC., a Delaware ) Corporation, AMAZON DIGITAL SERVICES, ) LLC, a Delaware Limited Liability Company, ) PRIME NOW, LLC, a Delaware Limited ) Liability Company, and WHOLE FOODS ) MARKET SERVICES, INC., a Delaware ) Corporation ) ) Defendants. ) AMENDED COMPLAINT FOR PATENT INFRINGEMENT Plaintiffs Freshub, Inc. and Freshub, Ltd. (together “Plaintiffs” or “Freshub”) jointly file this Amended Complaint for Patent Infringement and Demand for Jury Trial against Amazon.com, Inc., Amazon Digital Services, LLC, AmazonFresh, LLC, Prime Now, LLC, and Whole Foods Market Services, Inc. (collectively “Amazon” or “Defendants”) and allege as follows: THE PARTIES 1. Freshub, Inc. is a Delaware corporation with its principal place of business at 29 South Third Street, Suite 1C, in Brooklyn, New York. Freshub, Inc. is a wholly owned subsidiary of Freshub, Ltd. Freshub, Ltd. is an Israeli limited liability company with its principal place of business in Giv’at Shmuel, Israel. Freshub, Ltd. is a subsidiary of Ikan Holdings, LLC (“Ikan”). 1 Case 1:19-cv-00885-ADA Document 30 Filed 09/18/19 Page 2 of 59 2. Amazon.com, Inc. is a Delaware corporation which maintains its headquarters at 410 Terry Avenue North in Seattle, Washington. Amazon.com, Inc. may be served through its agent for service of process, Corporation Service Company, 251 Little Falls Drive in Wilmington, Delaware.
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